River Shenogh: the main source of water for the villages of Shenogh and Teghut. This river will be contaminated and its course altered should the planned mining waste reservoir (tailings dump) on its bank become a reality.

Republic of Armenia’s legislation on the Preservation of Nature, Article 11, states: “Every citizen has the right to live in a clean environment, and in case the later fails, then he/she has the right to be considered as a victim of an environmental disaster”. Also, Article 15 states: “Enterprises are obligated to guarantee environmental safety according to existing standards, [obligated] to secure the uninterruptible and efficient functioning of cleaning equipment, structures and stations, by means of neutralization of harmful wastes, by means of investing into environmentally harmless technologies and into water recycling systems. It is forbidden to allow the operation of those objects, which do not guarantee the execution of all environmental requirements. When such objects are given operation permits, the [permitting] committee chairman and committee members are subject to civil and criminal prosecution”.

In recent years, the laws are being bypassed and even manipulated to suit the interests of mining companies.

TeghutWhen the shortcomings of the Vallex Group of Companies’ plan to mine copper-molybdenum deposits inside the Teghut forest, near the vicinity of Teghut and Shenogh villages, became clear, especially that the proposed plan is violating several international conventions and the laws of the Republic of Armenia (RA), we were hoping that the Ministry of Nature Protection (MONP) will not accept the mining plan. However, to our surprise, MONP accepted and approved the plan without an independent study of the plan – without performing an independent environmental impact assessment. The Greens Union of Armenia has performed and published an analysis of the company’s plan and finds the plan to be false and incomplete in its environmental impact and risk assessment, therefore the plan should have been rejected by MONP. This fact alone leads us to conclude that there exists a collusion between the Vallex Group (which includes the Armenian Copper Program – ACP) and certain officials in MONP, in particular the departed Minister.

A very important issue here is that sacrificing the richly bio-diverse Teghut forest to mining will serve as a precedent for further sacrifices… Right now, mining exploration work is being carried out inside several other forests.

DrembonDrembon, in Artsakh, is an active mining site, where Vallex Group is mining copper and gold. Without investigating and/or studying, several reporters have broadcasted that all the tailings dumps/reservoirs at Drembon are structurally very safe, because, they’ve stated, that even though the locally expected earthquake tremor can reach an intensity of up to 4.5, the reservoir dams are made of reinforced concrete and are built to withstand an earthquake intensity of up to 9.0 (on the European MSK scale of 12 grades). Also, these same reporters have stated that the reservoir floors are waterproof, and similar other disinformation. Meanwhile, any visitor can see that the walls of these reservoirs are not made of concrete but are earth mounds, and the official earthquake map of Karabagh (MSK-64, 1997) shows that the local earthquake strength may reach up to 9.0. Moreover, the famous Sarsang water reservoir, located right next to the mine tailings dump, has an earthquake fault passing through it. Thus, at any time during an earthquake, toxic wastes from the tailings reservoir/dump can spill into the water reservoir. Furthermore, the floors of the tailings reservoirs are not waterproof. In fact, during an official visit to Drembon, from June 22 – 24th, organized and paid by The Vallex Group, to educate the public, including reporters and NGO representatives, about the company’s mining methods, the Greens and other visitors witnessed a new tailings dump being created right on the surface of the earth - the tailings are dumped over the grass and over the stumps and roots of the newly cut trees – something impermissible by law (cows were pasturing right next to these dumps.)

Alaverdi

Akhtala Vank and Tailing Dump: The church-fortress in the village of Akhtala was built in the 13th century to protect residents from foreign invaders. The threat to residents is now from within - from mining companies that are dumping copper mine tailings in the pit below the church.

On July 4th, the Minister of MONP, organized a visit/tour of the copper smelter at Alaverdi in order to familiarize himself and the public with the situation there closely. Again, invited were several reporters, who completely missed reporting a very good speech by Mr. Ara Babloyan, Chairman of the National Assembly Committee on Social, Health and Nature Protection Issues. During his speech, Mr. Babloyan made the point that under current economic conditions, it is very important to have the 600 plus workplaces at the Alaverdi smelter, however, there is a need to make serious calculations in order to decide whether it is worth keeping these workplaces at the expense of the loss of health of the local population, and at the expense of caring for thousands of disabled people. He called upon the plant owners to use proper emission control technology before considering the expansion of the plant production capacity. In contrast, certain representatives of non-profit organizations are expressing just the opposite view - justifying the necessity of operating the Alaverdi smelter the way it is being operated currently and the necessity of mining at Teghut (for example, such views were expressed by the leader of an NGO, about 2 months ago, on Armnews TV channel).

Note that the copper concentrate, which is produced by crushing the ore, then followed by an inefficient floatation extraction process carried out at various mine locations, is brought to the Alaverdi smelter, where the copper concentrate, which contains about 28% copper, in the form CuS2 , plus other elements, is smelted in the furnace at very high temperatures producing a slag which contains copper mixed with other metals (silver, gold, etc.), and, at the same time, volatile impurities such as arsenic, mercury, and sulfur are driven off into the air, the sulfur being removed as sulfur dioxide. All of the air emissions cause enormous damage to nature and to human health. The slag is exported without any further processing. Further extraction of metals from the slag should be and can be carried out locally using technologies, which are much less harmful to the environment than all the previous processes combined, such as for example, the electrolytic refinement process. This further extraction step will produce clean copper, gold, silver, rhenium and other rare metals. Note that the new processes produce relatively low volumes of gas, which, being high in sulfur dioxide, is well suited to the production of sulfuric acid. New smelters are designed to capture 90 percent or more of the sulfur contained in the feed materials.

The Politics of Pollution

The Vallex Group of Companies’ leaders have linked all three issues – mining in the Teghut forest, mining operation at Drembon and saving the city of Alaverdi from an environmental catastrophe - together. On numerous occasions, during discussions with the public, at open forums and public hearings, company leaders have stated that mining the copper-molybdenum deposits in Teghut will allow them to expand the production capacity of the smelter in Alaverdi and consequently will allow them to install emissions control technology, thus saving the city’s air from pollution, while the mine at Teghut will be operated similar to Drembon !!! These statements obviously do not correspond to reality. (To begin with, the mine at Teghut is planned to be an open-pit operation, while the mine at Drembon is a closed mine – uses tunnels). How can the required emission controls be tied to the issue of mining in Teghut ? About 12 years ago, the smelter owner signed an agreement with the government of RA to rehabilitate the smelter. Was there a provision in that agreement to condition the rehabilitation of the smelter to the mining in Teghut? And, why has the owner been allowed to pollute the air of the city of Alaverdi and the surrounding populated areas for over 10 years?

One of the owners of the company, Mr. Mejlumian, has stated at public hearings that if the company were given the opportunity to produce annually 100 – 120 thousand tons, instead of the current 10 – 12 thousand tons of slag copper (copper mixed with other metals), then it will be possible to have an environmentally safe smelter in the town of Alaverdi. According to him, in the beginning years, the Teghut mine will produce enough ore equivalent to 30 thousand tons a year of slag copper, but in later years the mine production will double and triple. Thus, at present levels of copper production, installing emissions control technology is impossible, since in that case operating the smelter will become unprofitable. In other words, if copper deposits in Teghut can’t be exploited, then the smelter must be shut down and the company will leave Armenia, according to Mr. Mejlumian.

Current technologies allow the capture of sulfur dioxide emitted during the smelter operation and produce sulfuric acid, which is utilized widely in industry. Mr. Mejlumian justifies the fact that his company does not attempt to make sulfuric acid and thus allows sulfur oxides to escape into atmosphere, by the apparent lack of demand for the 40 thousand tons of sulfuric acid that the company would be making if it were to capture all of the sulfur emitted. (According to him the demand is less than 10 thousand tons a year). Yet, the Valex Group has declared that it has bought sulfuric acid producing technology at a cost of 3 million dollars. So, if the company cannot sell the currently possible production of 40 thousand tons of sulfuric acid annually, how is it going to sell the greater amount of sulfuric acid when it expands its copper production ? (Actually, according to the Department of Soils Remediation and Use of the Agriculture Ministry, there are about 50 thousand hectares of salinized soils in Armenia, which would require 3 million tons of sulfuric acid for remediation.)

The Vallex Group must take steps to improve the standards of its operations and thus, win the trust of the population and of the government before considering new ventures or expanding the old ones. In the year 2006, for example, as a result of the smelter operation, 26.7 thousand tons of sulfur dioxide was released into the atmosphere, while the annual permissible limit for that chemical is 1.18 thousand. It turned out that MONP has given the Vallex Group a temporary permit to release 15.6 thousand tons of sulfur dioxide annually, thus helping the company to avoid hefty fines for exceeding permit levels. This was done to save the company some money so that the savings could be invested in installing emissions control equipment in order to meet the emissions standards eventually. The temporary permit expires at the end of the year 2008, while no steps have been taken toward installing emissions control equipment. Moreover, in 2006, the annual rate of emission of sulfur dioxide has increased by 2,546 tons compared to the 2005 levels. Also, last year, in 2006, in addition to sulfur, the smelter has released into air 12 tons of arsenic, 2.9 tons of lead, 104.7 tons of particle dust, 41 tons of zinc and over 2 tons of copper. (Compared to 2005, air emissions of heavy metals have increased by 23.81 tons.)

The emissions figures are official, since they are quoted by MONP. However, officials at MONP are not sure whether these figures are a result of sampling and analysis or are deduced from calculations based on chemical processes at the plant. These numbers originate from the plant operators, and MONP has not carried out any independent assessments of air emissions of the smelter. Note that plant operators are not motivated to show their worst level of emissions or any other discharge into the environment.

While, during the first 10 years of the smelter’s operation, its emission levels were made acceptable by special permitting from MONP, after May 2nd of 2005, these levels acquired legal acceptance when the National Assembly amended the Law on Nature Protection and Nature Usage Fees by setting new temporary standards on air emissions of toxic substances. In spite of this show of good will from the part of the government, the Vallex Group threatens frequently at public meetings/forums that it will shut down the smelter, if pressed to carry out air emissions control measures, because these measures “don’t cover their costs”, as states one of the owners, Valery Mejlumian. Meanwhile, the inhabitants of the city of Alaverdi continue to suffer. For how long do the inhabitants, especially the children, have to take medication before going to bed in order to cough less (as a result of the fumes from the smelter stacks), so they could go to sleep? How can these people survive under the circumstances ? Sooner or later, at least one individual will take the company to court and demand compensation for damaging his and his children’s health.

Yet, in spite of all the problems associated with its operations, The Vallex Group has managed to win a certain degree of media support.

In the beginning, the media showed a great deal of attention and concern regarding the Teghut forest issue, for example, by publishing numerous articles and broadcasting shows in favor of saving the forest. However, during the past 5 – 6 months, media outlets such as “Golos Armeni”, “Novoye Vremya”, “Iravunk (The Right)”, “Hayots Ashkharh”, “Delovoy Express”, “ArmNews”, “Armenpress” and others have begun issuing biased articles in favor of mining at Teghut.

This media bias/polarization became quite evident during a recent trip, June 22 – 24, to the mine at Drembon in Artsakh, organized and paid for by the Valex Group, where many reporters and representatives from various non-profit organizations were invited to participate. Afterwards, these reporters and representatives from various environmental organizations began broadcasting praise regarding the company’s proper mining methods at Drembon, such as the tunneling method of mining (as opposed to the open-pit mining method), the sealing/ closing of the exhausted tunnels/cavities with concrete (as opposed to abandoning them without closure), the neat and clean state of the ore processing plant nearby, etc., all of which had inspired awe among the trip participants. However, these same people also broadcasted misrepresentations of other issues related to the mining methods at Drembon, see section on Drembon.

Another instance of misrepresentation appeared in “Hayots Ashkharh”, 06.07.2007, where a reporter wrote that while touring inside the Teghut forest with the Minister of MONP, he/she did not see any cut trees in the forest of Teghut, “neither in areas where exploration drilling is being carried out, nor in the neighborhoods of the roads inside the forest; no logging evidence that can be observed from the roads was observed, no logging associated with the mine exploitation was observed”. Obviously, a report like this can mislead the public.

Conclusion

Thus, not only the laws are being bypassed, even manipulated to suit the interests of mining companies, but also there is a great lack of interest on the part of government officials in alternative development plans, instead of mining programs. For example, for Teghut and Shenogh villages, why can’t agricultural development be considered as a viable alternative to mining? After all, it was only two decades ago when that area had a profitable agricultural production. Why can’t that be restored and expanded? Instead, metals are being exported at the price of polluting/destroying the wilderness, the agricultural land, the water resources and the public health.